Appeal from conditional approvals.

(g) Any appeals filed pursuant to this Code section may not challenge the correctness of the information provided to the commissioner by the state auditor pursuant to Code Section 48-5-274. History. Code 1981, § 48-5-348, enacted by Ga. L. 1988, p. 1763, § 1; Ga. L. 1991, p. 728, § 7; Ga. L. 1992, p. 2494, § 8; Ga. L. 2000, p. 1683, § 8. Editor’s notes. Ga. L. 1992, p. 2494, § 10, not codified by the General Assembly, provided, in part: “County tax digests that were conditionally approved or disapproved by the commissioner for tax year 1991 in accordance with Article 5A of Chapter 5 of Title 48 of the Official Code of Georgia Annotated as it existed on January 1, 1992, shall be considered conditionally approved for each succeeding year beginning January 1, 1992, until such time as the first digest review year occurs for the county under the provisions of this Act.” Ga. L. 2000, p. 1683, § 11(c), not codified by the General Assembly, provides that Sections 2 through 10 of the Act shall be applicable to the 2000 tax digests and any subsequent tax digests. JUDICIAL DECISIONS Editor’s notes. In light of the similarity of the statutory provisions, decisions under Ga. L. 1966, p. 45, § 1, former Code 1933, §§ 91A-1413 and 91A-7001, and former Code Section 48-5-271 are included in the annotations for this Code section. Commissioner’s determination must be upheld unless the commissioner’s actions are deemed to be unreasonable, beyond the commissioner’s authority, or constitute an abuse of discretion. Fulton County v. Strickland, 251 Ga. 473, 306 S.E.2d 299, 1983 Ga. LEXIS 846 (1983) (decided under former O.C.G.A. § 48-5-271). Commissioner’s order upheld absent certain circumstances. — Commissioner’s order that assessments contained in a given county tax digest be increased or decreased by certain percentages must be upheld unless the commissioner’s actions are deemed to be unreasonable, beyond the commissioner’s authority, or constitute an abuse of discretion. Strickland v. Douglas County, 246 Ga. 640, 272 S.E.2d 340, 1980 Ga. LEXIS 1233 (1980) (decided under former Code 1933, § 91A-1413). County may seek review of commissioner’s exercise of discretion in making adjustments in county tax digests. Strickland v. Douglas County, 246 Ga. 640, 272 S.E.2d 340, 1980 Ga. LEXIS 1233 (1980) (decided under former Code 1933, § 91A-1413). Differences of opinion insufficient for review of commissioner’s determination. — Individual taxpayers have no right under state law to challenge factual decisions of the commissioner, within the commissioner’s statutory responsibility, in equalizing the digests of the various counties. To permit such a challenge would create chaos in the tax affairs of the state. Adams v. Smith, 415 F. Supp. 787, 1976 U.S. Dist. LEXIS 14487 (N.D. Ga. 1976), aff'd, 568 F.2d 1232, 1978 U.S. App. LEXIS 12338 (5th Cir. 1978) (decided under Ga. L. 1966, p. 45, § 1). Differences in opinion regarding what is reasonable uniformity of tax digests are not sufficient to bring the commissioner’s determination in a given case within range of judicial review, unless a manifest abuse of discretion, or arbitrary or capricious conduct on the commissioner’s part is shown. This is a question of law for the court. Strickland v. Douglas County, 246 Ga. 640, 272 S.E.2d 340, 1980 Ga. LEXIS 1233 (1980) (decided under former Code 1933, § 91A-7001). Standing to challenge factual decision. — Individual taxpayers have no right to challenge the factual decisions of the State Revenue Commissioner in equalizing the digests of various counties. Board of Tax Assessors v. Clary, 161 Ga. App. 828, 290 S.E.2d 110, 1982 Ga. App. LEXIS 2052 (1982) (decided under former Code 1933, § 91A-1413). Challenge by individual taxpayer to decisions affecting classes of property. — Commissioner makes decisions which affect classes of property. Although individual taxpayers ultimately are affected by the commissioner’s decisions, Georgia law does not allow an individual taxpayer individually to sue the commissioner to challenge the commissioner’s decision on any particular class of property. The rationale is that a decision on a class of property affects many people other than an individual taxpayer and an individual taxpayer should not be allowed to enjoin an action of the commissioner which affects an entire class of taxpayers. Adams v. Smith, 415 F. Supp. 787, 1976 U.S. Dist. LEXIS 14487 (N.D. Ga. 1976), aff'd, 568 F.2d 1232, 1978 U.S. App. LEXIS 12338 (5th Cir. 1978) (decided under Ga. L. 1966, p. 45, § 1). Remedies available to individual taxpayers. — Any objection to an adjustment by the state revenue commissioner or failure to make an adjustment must come from the county board of tax assessors. However, an individual remedy is not always unavailable to an individual taxpayer, who may obtain an injunction against the commissioner. While the general rule is that individual taxpayers cannot bring suit against the commissioner, when the orders complained of are void and illegal because they do not follow the mandate of the Acts nor of the constitutional provisions under which they purportedly were issued such suits may be authorized. Adams v. Smith, 415 F. Supp. 787, 1976 U.S. Dist. LEXIS 14487 (N.D. Ga. 1976), aff'd, 568 F.2d 1232, 1978 U.S. App. LEXIS 12338 (5th Cir. 1978) (decided under Ga. L. 1966, p. 45, § 1).